Christina Development Corporation ("Christina") respects the sensitive nature of any personal information that is provided to us by you or about you. We have created this Privacy Policy to demonstrate our commitment to the privacy of that information, including information provided by those who visit our website (the "Site") or provide information to Christina to obtain information about or engage in our services ("Services"), or contact us. This Privacy Policy describes our information collection, storage and disclosure practices regarding how we collect and use Personal Information.
California residents should consult the section titled "Your California Privacy Rights" for rights that apply to them.
We reserve the right to change this Privacy Policy at any time. In the event we make changes to this Privacy Policy, such policy will be re-posted in the "Privacy" section of our Site with the date such modifications were made indicated on the top of the page or we may contact you to inform you about the revisions with a link to the revised Privacy Policy. All changes are effective on the date listed at the top of this page and will apply to all information that we have about you. Your continued use of the Site or Services after any change is posted indicates your acceptance of the changes and your continued consent to our processing of your Personal Information. If at any point you do not agree to any portion of this Privacy Policy then in effect you should immediately stop using the Site and Services. Because this Privacy Policy contains legal obligations, we encourage you to review this Privacy Policy carefully. If you have any questions concerning this Privacy Policy or our information collection, storage and disclosure practices, please contact us at [email protected].
Personal Information That We Collect and How We Use It
Christina collects personal and financial information from you when you visit the Site or provide us directly with such information. "Personal Information" is information that may be used to directly or indirectly identify you, including your name, email address, physical address, phone number or other information about you. The majority of such Personal Information is collected by us during the registration and/or application process and, while some terms are optional, most are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Site, but keep in mind some of the information will be required if you wish to partake in the Services that we provide.
In general, the type of Personal Information we collect includes, but is not limited to:
- Personal Information required to verify your identity;
- Personal Information to contact you;
- Personal Information necessary to assess your eligibility to utilize the Services on the Christina platform; and
- Un-identifiable and aggregated Personal Information pertaining to your Site visits that help us maintain the appropriate features, functionality and user experience.
More specifically, investor registration will require you to provide basic Personal Information. Such information typically includes your name, e-mail address, home address and phone number, date of birth, social security number and/or tax identification number, employer and job title. Christina uses this Personal Information to: (i) enable you to log into the Site; (ii) establish your ability to view offering materials and to make investments through the Site (for U.S. residents such ability is restricted to "accredited investors" with a certain level of annual income or net worth); (iv) verify that you are at least 18 years of age; (iv) guard against potential fraud; (v) contact you if there is a problem with your account; and (vi) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other company updates.
Financial Data
When you subscribe to make an investment in one of the offerings on the Site, you will again be asked for your Personal Information. You will also be required to provide financial data, such as your bank routing number and bank account number, to enable us or issuers to utilize your bank account to originate funds transfers and make subsequent investment disbursements to you.
Non-Identifiable Data and Aggregated Personal Information
Regardless of whether you submit information to us, Christina may send one or more "cookies" to your computer. Cookies are small text files placed on your web browser when you visit our Site that store information on your computer, such as your Site preferences. We use cookies when you sign in to keep track of your personal session, including some account identifiers to ensure that you are the only person making changes to your account. We also use cookies to track your activity on the Site as a unique person. For security purposes, all of this information is stored in encrypted form.
You can set your web browser to inform you when cookies are set, or to prevent cookies from being set altogether. Please note, however, that if you decline to use cookies, you may experience reduced functionality and slower site response times. In some instances, declining to use our authentication-related cookies may prevent you from using the Site entirely.
Christina or our service providers may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, "click stream" transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. Christina may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Site based on the needs of our users.
How and When Your Information Is Shared With Other Parties
Christina does not sell, trade or license Personal Information about its users for marketing purposes. We do, however, work with a number of trusted partners who perform vital functions as part of our operations.
Additional Sharing of Investor Information
We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing, reporting, tax documentation, electronic signature custody or escrow services. Personal Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your Personal Information private and secure.
We may share your Personal Information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your Personal Information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your Personal Information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our services, or to protect the rights, property or personal safety of Christina, its users, or others.
We may share your Personal Information in connection with a corporate reorganization or transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Notifications and Communications from Our Site
Communications Regarding Our Services
If you provided your Personal Information to us, we may send you email notifications and other communications from time to time. Some notifications are communications relating to us and our Services. You may "opt-out" from receiving such communications by following the "Unsubscribe" instructions provided in the email.
From time to time we will also send user surveys, requests for user feedback regarding user experience and Site operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback or accepting any offer is strictly voluntary. If you do not wish to receive these surveys, user feedback emails, and/or marketing offers, please opt out in any offer email you receive from us.
Legal or Security Communications
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection. In other cases, these notifications involve changes to various legal agreements, such as this Privacy Policy. Generally, you may not opt out of such emails.
Communications Regarding Our Services
If you contact us we may send you communications regarding our Services in response to your inquiries. Generally, you may not opt out of such emails.
Other Communications
When you register as an investor, you will receive e-mails that confirm specific actions you requested. These will include e-mails to which you must respond to complete your registration and notifications confirming your registration. Thereafter, you will receive e-mails when a new investment opportunity is offered, as well as updates concerning the progress of the funding of such offering and/or other relevant information if you make an investment through the Site. Christina will also send you confirmations of the investment as well as occasional updates as to the status of that investment and the timing of distributions relating to that investment.
We may also send you responses to e-mails you send us, if appropriate.
Deleting and Correcting Your Information
If you have provided us directly with your Personal Information and want us to delete your Personal Information, please contact us at [email protected] with your request. We will take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
We urge you to review your Personal Information regularly to ensure that it is correct and complete. If you believe that any of your information is correct, of if you have questions regarding this Privacy Policy, please contact us at [email protected].
Personal Information Retention
We retain the Personal Information we receive as described in this Privacy Policy for as long as a you use the Services or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Links to Other Sites
If you follow any links that direct you away from the Site, including links to social media sites, among others, this Privacy Policy will not apply to your activity on the other sites you visit. We do not control the privacy policies or the privacy practices of any third party.
International Users
Although this Site is intended solely for users within the United States, it may be accessed by users located outside the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States, and that by providing your Personal Information on or through the Site then you consent to that transfer.
Security Policy
We limit access to the Personal Information that we have about you to those employees who have a specific business reason for accessing such information. We employ commercially reasonable physical, electronic and contractual safeguards to protect the confidentiality and security of Personal Information transmitted to us.
If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at [email protected].
Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Site. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our technical support staff.
Children Under 13
The Site is restricted to the use of adults over the age of majority in their place of residence. No portion of the Site is directed to children under the age of 13. Consequently, we do not knowingly collect personal identifying information about or from any person we know is a child under the age of 13. If we learn that we have collected Personal Information from a child under age 13 we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at [email protected].
Your California Privacy Rights
The following section pertains to the rights of individuals or households in California ("California consumers").
Civil Code Section 1798.83
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer's Personal Information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.
Rights under the CCPA
The CCPA (California Civil Code Section 1798.100 et seq.) provides California consumers with additional rights regarding Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. The categories of Personal Information we collect are generally described above but differ for individual consumers depending on the Services used by such consumers.
Under the CCPA, qualifying California consumers may have the following rights:
Right to Know and Right to Delete.
A California consumer has the right to request that we disclose what Personal Information we collect, use, disclose and sell. A California consumer also has the right to submit requests to delete Personal Information.
When we receive a request to know or delete from a California consumer, we will confirm receipt of the request within 10 business days and provide information about how we will process the request, including our verification process. We will respond to such requests within 45 days.
Right for Disclosure of Personal Information.
A California consumer may also submit requests that we disclose specific types or categories of Personal Information that we collect.
Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, customers' accounts with us, or the security of our systems or networks. We also will not disclose California consumers' social security numbers, driver's license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers.
Submitting Requests
If you are a California consumer and would like to make any requests under the CCPA, please direct them as follows:
Christina Development Corporation
[email protected]
22653 Pacific Coast Highway
Malibu, California 90265
Verifying Requests
If we receive any request we will use a two-step process for online requests where the California consumer must first, clearly submit the request and then second, separately confirm the request.
In submitting a request, a California consumer must provide sufficient information to identify the consumer, such as name, email address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver's license numbers, account numbers, credit or debit card numbers, medical information or health information with requests. If requests are unclear or submitted through means other than as outlined above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.
California Do Not Track Disclosures
Although some browsers currently offer a "do not track ('DNT') option," no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers' DNT signals.